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Interpretation Response #03-0142 ([University of Hawaii at Mãnoa] [Mr. Tim O"Callaghan])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: University of Hawaii at Mãnoa

Individual Name: Mr. Tim O"Callaghan

Location State: HI Country: US

View the Interpretation Document

Response text:

Oct 6, 2004

Mr. Tim O’Callaghan                 Reference No. 03-0142
Hazardous Materials Management Officer
Environmental Health and Safety Office
University of Hawaii at Mãnoa
2040 East-West Road
Honolulu, HI 96822

Dear Mr. O’Callaghan:

This is in response to your follow-up letter and our July 1, 2004 telephone conversation concerning the transport of hazardous waste by vessel from Hawaii to the continental United States under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You asked if a shipper may use a limited quantity exception to transport a waste hazardous materials under the HMR provided he or she complies fully with the provisions contained in the exception for that material. In your example, you stated that you want to use the limited quantity exception in § 173.152 to transport two-l0 pound (4.54 kg) glass inner packagings of “Waste Potassium nitrate, 5.1 (oxidizer), UN 1486, PG III.” We apologize for the delay in responding and any inconvenience this may have caused.

Your understanding is correct. When offering or transporting a waste hazardous material by vessel between or within the United States and its territories, a shipper may use any HMR exception that is authorized for that material in Column (8A) of the Hazardous Materials Table ( 172.101 Table). Section 173.152 permits 10 pound (4.54 kg) glass inner packagings of waste potassium nitrate to be transported as a limited quantity by vessel when placed inside a strong outer packaging in conformance with the applicable requirements prescribed in § § 173.24, l73.24a, and 49 CFR Part 176. The completed package must weigh no more than 30 kg (66 pounds). On the shipping paper, the description for a material offered for transportation as a limited quantity must include the words “Limited Quantity” or “Ltd Qty” following the basic description (see § 172.203(b)). Packages must be marked with the proper shipping name for the material as shown in the Hazardous Materials Table (see 172.30 1(a)). Under the HMR, the identification number, hazard warning label, and placard are not required on packages that contain only limited quantities.
If all or part of the waste potassium nitrate’s transportation is by vessel, the material may be transported as prescribed under the International Maritime Dangerous Goods Code (IMDG Code) provided the package conforms with the requirements prescribed in § 171.12 of the HMR. The applicable regulations for limited quantities transported by vessel are found in Volume 2, Chapter 3.4, of the IMDG Code.


I hope this satisfies your request.



Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards.


Regulation Sections

Section Subject
173.12 Exceptions for shipment of waste materials